Background
Peyman Roshan appealed a district court order dismissing his claims against Chika Sunquist, Douglas McCauley, and the California Department of Real Estate. The underlying dispute involved a California State Bar disciplinary order that the California Supreme Court had declined to review.
The court’s reasoning
The panel reviewed questions of sovereign immunity and the Rooker-Feldman doctrine de novo. The court found that the California Department of Real Estate is a state agency and that California has not waived sovereign immunity. The court rejected the argument that the Supreme Court silently modified this doctrine in DeVillier v. Texas. Regarding the remaining claims, the court applied the Rooker-Feldman doctrine, which prohibits federal courts from hearing suits that function as de facto appeals of state court rulings. The court determined that Roshan’s claims sought to overturn the California Supreme Court’s denial of review, making them analogous to those dismissed in District of Columbia Court of Appeals v. Feldman.
What it means going forward
The decision reinforces the Eleventh Amendment bar against suing state agencies in federal court absent a clear waiver and confirms that federal courts cannot serve as appellate bodies for state court decisions under the Rooker-Feldman doctrine.
Podcast (federal-narrative-summaries): Play in new window | Download